The CCC’s review of the Government’s Clean Growth plan is out. And the verdict? While ambitious in tone, it’s riddled with policy gaps. And yet again, aviation is on the list of sectors needing urgent attention.

Policies to meet existing commitments in the Government’s strategy are lacking. There are inadequate measures to deliver on: buildings energy efficiency: low-carbon heat; surface transport; power generation, agriculture and land use; and aviation.

Even if all existing commitments were met, there remains a gap that must urgently be closed in order to meet the fourth and fifth carbon budgets. Delay to publication of the strategy means that “time has already been lost” in which to make the right investments.

The Government must plan to meet the carbon budgets through domestic action, not relying on carbon offsetting or on banking from previous budgets; and

As we’ll almost certainly need to ratchet up our legal climate commitments in order to meet the Paris Agreement, the UK should be over-delivering, not under-delivering on carbon budgets as currently set.

The CCC’s longstanding advice is that emissions from international aviation, while not formally included in carbon budgets, must be allowed for by setting aside 37.5 Mt from the total carbon budget allowed in 2050 (around a quarter of the allowable CO2 by that date). Yet as today’s report notes, the government has made ‘no progress’ in setting out a policy to achieve this.

The next available opportunity to fix this, suggests CCC, is by way of the aviation strategy, launching for consultation this year from the Department for Transport. This, the CCC spells out:

“will need to include a plan to limit UK aviation emissions to the level assumed when the fifth carbon budget was set (i.e. around 2005 levels by 2050, likely to imply around a 60% potential increase in demand), supported by strong international policies.”

So what about Heathrow?

Meanwhile, with its fingers apparently in its ears, the Government is ploughing on with plans for a third Heathrow runway, and the airport, which has launched a consultation on the project today, has claimed that “the planning process for Heathrow expansion is now firmly underway” despite the fact that parliament has yet to take a decision on the plan. A vote in the house is expected before the summer – before, in other words, there’s likely to be any aviation emissions strategy in place.

As the Airports Commission cannily argued, the CCC’s recommendation that a 60% passenger growth may be possible for aviation could in theory allow for a whole new runway. The problem is that Heathrow isn’t the only UK airport that wants to grow. The large majority of the UK’s airports, in fact, have ambitious growth plans, and most of these don’t need Government approval or runway expansion to deliver them. The latest official aviation forecasts (published quietly and late) indicate that even without expansion there will be around 78% passenger growth expected by 2050 (compared to 2005), and that with a new runway at Heathrow the figure will be more like 89%. (And for the record, the figure for Gatwick expansion is not far behind at 88%.)

Any answers?

Squeezing aviation emissions down to a level compatible with the Climate Change Act will be a challenge even without runway expansion. The sector, as the CCC reiterates today, falls firmly into the ‘difficult to reduce’ category when it comes to CO2. There are tough conversations to be had – about the price of flying, the prospects (and costs) of ramping up technology improvements, and what kind of demand constraints may be necessary in relation to existing infrastructure.

It surely stretches credulity to think that a new runway could be shoehorned into this question without putting the target effectively out of reach, which is presumably why the Government is refusing to talk about it.

And as today’s report makes clear, the chance that other sectors will over-deliver to allow for extra emissions for aviation is pretty much out of the question.